Nathan P. Viebrock

CFPB investigation of debt sales and collections activity Represented financial services company in investigation by the Consumer Financial Protection Bureau related to the company’s debt sales and collections activity. State Dept. of Commerce investigation of marketing and sales practices Represented international bank in investigation by the Minnesota Department of Commerce related to insurance marketing and sales practices. Federal and multistate enforcement/supervisory actions Represented financial services company in coordinated federal and multistate enforcement and supervisory action related to the company’s servicing and payment application processes. Policies and procedures review Conducted review of company’s debt sales and collection policies and procedures to ensure all practices were in compliance with the CFPB Debt Collection Examination Procedures. State regulator compliance guidance Guided financial services company through process of self-reporting errors to state regulators and designing consumer remediation review program to the satisfaction of consumers and regulators. Data security matters Managed financial services company’s handling of a sensitive data security incident that called for the company to inform consumers of the incident while minimizing the risk of potential future litigation related to the incident. Document execution and custody review Reviewed financial services company’s document execution practices and identified solutions for improving the effectiveness of document custody controls. Employee incentive pay programs Advised client on designing proper incentive pay programs for employees in their originations and collections departments.